Jefferson v. Benjamin
- David Doty
- 0:25-cv-02534
- U.S. District Court · District of Minnesota
- 2
In Jefferson v. Benjamin, Judge Doty denied plaintiff David Jefferson's request to appeal without paying the filing fee, finding that his appeal is legally frivolous.
Pro se litigants (people representing themselves) who seek to appeal a dismissed case without paying the filing fee. The ruling directly affects plaintiff David Jefferson.
What happened
In Jefferson v. Benjamin (Civil No. 25-2534), plaintiff David Jefferson asked the court to let him appeal his dismissed case without paying the required filing fee, a status available to people who cannot afford court costs under federal law (28 U.S.C. § 1915).
The court assumed Jefferson likely qualifies financially, since his application suggested he may not have enough income or savings to cover the full fee. However, fee-waiver status can still be denied if the appeal is not brought in 'good faith' — meaning the claims raised on appeal must have at least some arguable basis in law or fact. If an appeal is frivolous (entirely without merit), the law does not allow the fee to be waived.
Judge Doty found that Jefferson's appeal is frivolous, for the same reasons the court previously dismissed his underlying case. Because the appeal lacks any arguable legal or factual basis, Judge Doty denied the request to appeal without prepaying the filing fee. Jefferson may still pursue his appeal if he pays the required fee.
The detailed version
Case: Jefferson v. Benjamin, Civil No. 25-2534 (DSD/DTS), U.S. District Court, District of Minnesota. Judge: David S. Doty. Order dated: September 2, 2025.
Background
Plaintiff David Jefferson's case was previously dismissed by the court (see ECF No. 4). Jefferson then filed an application (ECF No. 13) to proceed without prepayment of fees on appeal — commonly called 'in forma pauperis' (IFP) status — under 28 U.S.C. § 1915 and Federal Rule of Appellate Procedure 24(a).
Legal Standard
To obtain IFP status for an appeal, an applicant must satisfy two requirements: (1) financial eligibility — demonstrating an inability to pay the full filing fee, 28 U.S.C. § 1915(a)(1); and (2) good faith — the appeal must not be frivolous, 28 U.S.C. § 1915(a)(3). Good faith is assessed objectively, not based on the appellant's subjective beliefs. Coppedge v. United States, 369 U.S. 438, 444-45 (1962). An appeal is frivolous — and thus not in 'good faith' — where it 'lacks an arguable basis either in law or in fact.' Neitzke v. Williams, 490 U.S. 319, 325 (1989).
Financial Eligibility
The court assumed, without definitively finding, that Jefferson is financially eligible, as his application indicated he may lack sufficient income or savings to pay the full filing fee.
Good Faith / Frivolousness
The court denied IFP status on the second prong. Citing the reasons set forth in its earlier dismissal order (ECF No. 4), Judge Doty found Jefferson's appeal to be frivolous — lacking any arguable basis in law or fact. The opinion does not restate those reasons; it incorporates them by reference.
Ruling
The application to appeal without prepayment of fees (ECF No. 13) is DENIED. Jefferson is not barred from appealing, but must pay the applicable filing fee to proceed.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.